Reinsurance Association of America
Reinsurance Association of AmericaSupportAdvocacy
Summary: The Reinsurance Association of America (RAA) supports the proposal's goals but requests specific revisions to clarify that well-capitalized insurance companies can serve as "eligible guarantors." They argue that the current rules create a competitive disadvantage for banks by failing to recognize the credit risk mitigation benefits provided by prudentially regulated insurance and reinsurance companies.
The Reinsurance Association of America (RAA) is pleased to submit the attached comments in response to the notice of proposed rulemaking, "Regulatory Capital Rule: Category I and II Banking Organizations, Banking Organizations With Significant Trading Activity, and Optional Adoption for Other Banking Organizations."